Admiralty – Jurisdiction – Quasi -Contractual Remedy

Petitioners paid money to respondent for prospective passage to Europe on his passenger vessel held out as a common carrier. When respondent failed to make the voyage or return the passage money, petitioners sued in admiralty for breach of contract. The libel was in the nature of indebitatus assumpsit for moneys had and received and wrongfully withheld by respondent. The district court held this an action based upon the breach of a maritime contract and therefore within the admiralty jurisdiction. The court of appeals reversed, on the ground that the action was in the nature of the common law indebitatus assumpsit for moneys had and received, and therefore the admiralty court had no jurisdiction. On certiorari to the Supreme Court, held, reversed. Even though the libel reads like indebitatus assumpsit, admiralty has jurisdiction provided the unjust enrichment arose as a result of the breach of a maritime contract. Archawski v. Hanioti, 350 U.S. 532 (1956).